This privacy policy explains how APEARS (“we”) uses any personal information we collect about you.

What information do we collect about you and why?

APEARS collects and uses personal data on the basis that it is in its legitimate interests to do so, for example to keep records of transactions and to provide a service to its customers.

From our website: We collect information you provide by filling in one of our online enquiry forms, and we will use this to keep you updated about APEARS’s activities and/or to perform the services you request. You may withdraw this consent at any time by emailing us or writing to us using the information at the end of this policy

From our clients: We collect information via our account application process and throughout our relationship with you in order to comply with regulation and for the purpose of performing our contract with you. The provision of your personal data is required in order to enter into a contract with us, however the provision of information for marketing purposes is voluntary. We may record and monitor phone calls made to or by us in order to comply with regulatory obligations. Automated decision making may be used in order to comply with our AML checks or to evidence that APEARS is providing a suitable and appropriate service to its clients.

How long do we keep this information?

If you are not a client of ours, we will keep your information for a year after we last heard from you. If you ask us to remove you from our marketing list, we may keep your personal details on an “opted-out” list in order to ensure that we do not market to you again.

If you are or were a APEARS client, we keep most of your information for 7 years after closure of your account. Where required by law or regulation, we keep documents relating to pension transfers indefinitely and recordings of telephone conversations with you for 5 years after they took place.

Who do we share your information with?

  • Our IT providers and services providers in order to provide and maintain the provision of our services;
  • Our appointed auditors, accountants, lawyers, stockbrokers, banks and other professional advisers, to the extent that they require access to the information to provide advice;
  • Fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
  • Any relevant regulatory authority where they are entitled to require disclosure;
  • If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
  • Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
  • If tax regulations require us to collect information about  tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions;
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets; or
  • If APEARS’s assets are acquired by a third party, in which case personal information held by it about its clients may be one of the transferred assets.

We will not lend or sell your information to third parties.


Internet communication, which includes email, is not secure. The protection of data by encryption is possible provided that the encryption method (protocol) used is current and the correct procedure for encryption and decryption is followed at all times.  We cannot accept any responsibility for unauthorised access by a third party or for the loss, theft or modification of data while it is being sent to us by email. For security purposes we may monitor emails received or issued by us.

Other websites

Our website contains links to other websites. This privacy policy only applies to our website. When you use a link to another website you should read the privacy policy of that site.

Changes to our Privacy Policy

We reserve the right to update this privacy policy at any time. When we make changes to this policy, we will amend the revision date at the bottom of this page. We encourage you to occasionally review this privacy policy to be informed about how we are protecting your information.

How to contact us

If you have any questions about our privacy policy or the information we hold about you please contact us at or by post at the address below:

GPO Box 4859

This policy was last updated in June 2018.

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